Match Fixing and Money Laundering
Jack Anderson
Professor of Law
Editor, International Sports Law Journal
School of Law
Queen’s University,
Belfast BT7 1NN
N. Ireland, UK
Email: [email protected]
@SportslawQUB
Introduction
This essay, as with many others in this collection, is premised on the following: a
conspiracy to fix or otherwise manipulate the outcome of a sporting event for
profitable purpose. That conspiracy is in turn predicated on the conspirators’
capacity to: (a) ensure that the fix takes place as pre-determined; (b) manipulate the
betting markets that surround the sporting event in question; and (c) collect their
winnings undetected by either the betting industry’s security systems or the
attention of any national regulatory body or law enforcement agency.
Unlike many of the essays in this collection, however, this contribution does not
focus on the “fix”– part (a) of the above equation. It does not seek to explain how or
why a participant or sports official might facilitate a betting scam through either onfield behaviour that manipulates the outcome of a game or by presenting others with
privileged inside information in advance of a game. Neither does this contribution
seek to give any real insight into the second part of the above equation: how such
conspirators manipulate a sports betting market by playing or laying the handicap
or in-play or other offered betting odds. In fact, this contribution is not really about
the mechanics of sports betting or match fixing at all; rather it is about the sometimes
under explained reason why match fixing has reportedly become increasingly
attractive as of late to international crime syndicates. That reason relates to the fact
that given the traditional liquidity of gambling markets, sports betting can, and has
long been, an attractively accessible conduit for criminal syndicates to launder the
proceeds of crime. Accordingly, the term “winnings”, noted in part (c) of the above
equation, takes on an altogether more nefarious meaning.
This essay’s attempt to review the possible links between match fixing in sport,
gambling-related “winnings” and money laundering is presented in four parts.
First, some context will be given to what is meant by money laundering, how it is
currently policed internationally and, most importantly, how the growth of online
gambling presents a unique set of vulnerabilities and opportunities to launder the
proceeds of crime. The globalisation of organised crime, sports betting and
transnational financial services now means that money laundering opportunities
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have moved well beyond a flutter on the horses at your local racetrack or at the
roulette table of your nearest casino. The growth of online gambling platforms
means that at a click it is possible for the proceeds of crime in one jurisdiction to be
placed on a betting market in another jurisdiction with the winnings drawn down
and laundered in a third jurisdiction and thus the internationalisation of gamblingrelated money laundering threatens the integrity of sport globally.
Second, and referring back to the infamous hearings of the US Senate Special
Committee to Investigate Organised Crime in Interstate Commerce of the early
1950s, (“the Kefauver Committee”), this article will begin by illustrating the long
standing interest of organised crime gangs – in this instance, various Mafia families
in the United States – in money laundering via sports gambling-related means.
Third, and using the seminal 2009 report “Money Laundering through the Football
Sector” by the Financial Action Task Force (FATF, an inter-governmental body
established in 1989 to promote effective implementation of legal, regulatory and
operational measures for combating money laundering, terrorist financing and other
related threats to the integrity of the international financial system), this essay seeks
to assess the vulnerabilities of international sport to match fixing, as motivated in
part by the associated secondary criminality of tax evasion and transnational
economic crime.
The fourth and concluding parts of the essay spin from problems to possible
solutions. The underlying premise here is that heretofore there has been an insularity
to the way that sports organisations have both conceptualised and sought to address
the match fixing threat e.g., if we (in sport) initiate player education programmes;
establish integrity units; enforce codes of conduct and sanctions strictly; then our
integrity or brand should be protected. This essay argues that, although these
initiatives are important, the source and process of match fixing is beyond sport’s
current capacity, as are the possible solutions.
1. The Link between Money Laundering, Sports Betting and Match Fixing
Focusing first on money laundering; in 2012, a Senior Financial Sector Expert in the
IMF’s Legal Department stated bluntly: “Money laundering is an essential
component of any profit-making crime, because without laundering, crime really
doesn’t ‘pay’” (Ashin, 2012, pp38-39). Money laundering is a process which
transforms the proceeds of crime (typically that made from the trafficking of drugs)
into assets that appear legitimate in nature e.g., property portfolios, luxury good
such as artworks or accounts at reputable banks. While the social cost resulting from
drug trafficking is evident, the associated societal cost resulting from the laundering
of drug monies is significant. The laundering of such “dirty” money perpetuates the
power and influence of such criminal enterprises by resourcing the bribing and
corruption of key political and law enforcement figures and thus it affords such
enterprises further protection in carrying out their “trade”. The activity also denies a
country’s exchequer significant tax revenue; destabilizes and deters legitimate
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enterprise and investment, and, in extreme cases, finances insurgency and even
terrorist activities.
The link between the proceeds of crime and money laundering can be seen clearly in
the most recent estimates on illicit financial flows globally. A 2011 United Nations
Office on Drugs and Crime (UNODC) meta-analysis of existing estimates has
suggested that criminal proceeds are, annually, now close to US$2.1 trillion or 3.6%
of global GDP. The best estimate for the amount available for laundering through
the international financial system is the equivalent to 2.7% of global GDP or US$1.6
trillion yearly (UNODC, 2011, p7). The starkest figures is however that the
“interception rate” for anti-money-laundering efforts at the global level remains
critically low: only 0.2% of the proceeds of crime laundered via the financial system
are seized and frozen (UNODC, 2011, p7).
Gambling platforms of various kinds (from gaming machines to casino gambling to
online sports betting exchanges) provide a unique conduit for laundering the
proceeds of crime such that they emerge as legitimate business revenue. The
characteristics that are most relevant include the following: liquidity is usually high;
the cash flow is fluid and easily internationalised online; global sports betting law
lacks harmony and enforcement is, in any event, uneven as aggravated by the fact
that there is a bewildering array of regulated and unregulated bookmakers available
to process bets; gambling winnings in some jurisdictions are tax free and/or can be
easily diverted offshore ; and the pay-out percentage, relative to investment returns
available in other financial services industries, are high (Fielder 2013).
In a 2011 report, SportAccord (a representative body for both Olympic and nonOlympic international sports federations as well as organisers of international
sporting events) took especial care to highlight the risks emanating for the last
named point above: the high pay out rate. The report reiterated that for organised
crime gangs money laundering is a “cost” of doing business, which they have
historically struggled to keep to below 30%; consequently, it is unsurprising that
given the high pay out rate available in sports betting (average pay out rates in the
sports betting industry have risen from less than 80% 15 years ago to a situation
where today online betting companies generally pay out over 92% of total amounts
staked) internet sports betting becomes an extremely attractive means of laundering
money. This in turn “gives criminals an interest in both the betting industry and
sports organisations” (SportAccord, 2013, p31). Using statistics similar to the
UNODC figures given above, SportAccord estimates that sports betting could now
be used to launder more than €11,000m worldwide and that the winnings of fixed
matches could represent up to €6.8bn or six times more than the total global trade in
illegal small arms (SportAccord, 2013, p37).
An interesting illustration of the above points was brought out in the annual report
of the US Congressional Executive Commission on China (2013, p190), which
assessed aspects of the gambling industry in Macau, the former Portuguese colony
and now a special administrative region of the People’s Republic of China. The eight
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square kilometre peninsula is a powerhouse in the international gambling industry
and in 2013 its 35 casinos brought in a record $45bn (£27.4bn) in takings, up 19%
from the previous year. The US Congressional report expressed serious concerns
about the lack of law enforcement and regulatory reporting mechanisms to combat
the laundering of large amount of money out of mainland China and through a web
of gambling promoters and intermediaries known as “junkets”. The US
Congressional report cited research estimating that a staggering US$202 billion in illgotten funds are channelled through Macau each year (US Congressional Executive
Commission on China, 2013, p190, fn49).
To recap, money laundering is an essential component to the further profitization of
transnational crime. In a scenario where, according to UN figures, 99.8% of
laundered criminal proceeds go unintercepted by law enforcement agencies, it
would be unsurprising if gambling was not used as a laundering mechanism and
especially as the betting returns can be relatively high in yield. It follows that the
temptation for criminal syndicates to enhance the laundering process, and their
yields, by fixing the sporting events on which they are betting, must be significant.
In turn, it becomes easy to understand why leading international law enforcements
agencies such as Interpol constantly remind international sporting bodies that
neither the source nor the gravity of the match fixing threat should be
underestimated. If international criminal syndicates are so successful at both (a)
trafficking drugs, weapons, commodities, wildlife, art and cultural property, human
organs and people across borders and (b) laundering the resulting proceeds, then the
integrity of sport can also and easily be trafficked and exploited for criminal gain.
Indeed, the Secretary General of Interpol has been quoted as saying:
“In recent years, match fixing has become a global problem…It permits
organized crime the opportunity to spread worldwide its illegal and violent
activities which include murder, extortion and assault and which cause tax
revenue and other losses of billions of dollars every year“ (Noble, 2013, ppvivii).
It must be admitted here that match fixing in sport, although almost always
motivated for illegal betting purposes, can and does take place in the absence of
money laundering but equally illegal betting and fixing of sports events can and
does, for the reasons previously outlined, lend itself to the laundering of money
originating from the proceeds of crime.
The next two sections of this essay illustrate the following: first, what has been
described is not a modern phenomenon because sports betting’s facilitation of
money laundering and/or the rigging of sporting events has a long and colourful
history; and second, that sport’s vulnerability as a channel for criminals to launder
the proceeds of their illegal activities is not just confined to gambling-related match
fixing but has an even wider corruptive base.
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2. The Kefauver Committee
In the immediate post-WWII era, and prior to the Korean War’s heralding of the
Cold War, American public opinion turned once more to internal matters of concern.
In 1949, the American Municipal Association an advocacy group representing
thousands of municipal authorities across the United States (and known today as the
National League of Cities), petitioned the US government to investigate the
perceived threat from organised crime and particularly that associated with the
Italian immigrant community (US Senate Historical Office 2013, p1). US Senate
Resolution 202 of 2 May 1950 facilitated the establishment of a five person committee
“authorized and directed to make a full and complete study and investigation of
whether organized crime utilizes the facilities of interstate commerce…in
furtherance of any transaction which are in violation of the law of the United
States…and, if so, the manner and extent which and the identity of the persons firms
or corporations by which such utilization is being made, what facilities are being
used, and whether or not organized crime utilizes such interstate facilities.” The
Committee, chaired by Senator Estes Kefauver, then began a 15-month investigation
across 14 major US cities in which it interviewed hundreds of witnesses in open
session (Wilson, 2011).
Kefauver was of no doubt that the key to the Committee’s deliberations, and thus its
principal investigative focus, would have to be on what he called “the lifeblood of
organised crime”: interstate gambling (US Senate Historical Office 2013, p2).
Through this “key”, Kefauver thought he would unlock a nationwide conspiracy
between Mafia families, corrupt politicians and crooked police officers (Moore,
1974). The hearings began in Florida on 28 May 1950 and soon revealed a political
and policing culture, and particularly in Miami, that not only tolerated extensive
illegal gambling dens in nightclubs, at restaurants and on sidewalk vending stalls
(US Senate Special Committee to Investigate Organised Crime in Interstate
Commerce, 1950, Hearings, Part 1 and Part 1a), but also crystallized into direct links
between illegal bookmaking syndicates and the then governor of the state, Fuller
Warren (US Senate Special Committee to Investigate Organised Crime in Interstate
Commerce, 1951, Final Report, pp73-76).
The New York hearings were particularly dramatic and focused on the so-called
“Prime Minster of the Underworld”, Frank Costello, also known to law enforcement
authorities across the United States as the key figure in the nation’s biggest illegal
gambling syndicate (US Senate Special Committee to Investigate Organised Crime in
Interstate Commerce, 1950, Hearings, Part 18). The evasive raspy-voiced replies
from Costello (which later influenced Marlon Brandon’s delivery in The Godfather)
eventually put Costello in jail for contempt (Wilson, 2011, pp733-734) but more
importantly revealed the sophisticated, interlinked nature of organized crime
families interests in gambling racketeering and secondary criminality including tax
evasion and money laundering (US Senate Special Committee to Investigate
Organised Crime in Interstate Commerce, 1951, Final Report, pp.2-73).
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Of other interest is that in the early stages of his career in the 1920s and coinciding
with the Prohibition era, Costello was closely associated with Arnold Rothstein, the
criminal financier widely reputed to have been involved in the 1919 Baseball World
Series fix (Katcher, 1994, pp138-149) and also with William “Big” Dwyer who in the
1920s was involved variously as an owner and/or rigger of National Hockey League
clubs and matches (Bruno, 2013, pp74-83). Indeed subsequently the experience
gained by Kefauver during these hearings was put into good effect a decade later
when the Senator led a series of hearings into the then state of professional boxing in
the US and the egregious fixing and rigging of championships in that sport under
the guise of the Mob-run International Boxing Council (Mitchell, 2009, pp184-191).
Despite the massive public interest generated by the Kefauver Committee’s hearings
(the live New York hearings attracted a TV audience of near 30 million viewers) the
Committee’s legacy was somewhat disappointing; for instance its principal
recommendation, the creation of a federal crime commission was, in effect, vetoed
by J Edgar Hoover at the FBI (Moore, 1974, 215). Nevertheless, the Kefauver
Committee’s recommendations did present a blueprint as to how cross-border illegal
gambling rackets might be confronted. In a specific sense, Kefauver correctly
identified that the illegal “bookie” empire, as he called it, had “two vulnerable points
within reach of [US] Congress’ power over interstate commerce: the essential flow of
specialized gambling information to the bookmaker [over interstate] wire services,
and this dependence on interstate [communication] facilities in placing lay-off and
come-back bets” (US Senate Special Committee to Investigate Organised Crime in
Interstate Commerce, 1951, Final Report, p88). The Committee drafted legislative
bills to strike at these points and, although never introduced, they remain instructive
because today international criminals make similar use of the opportunities offered
by the global, online financial system as powered by sophisticated computerised
data processing and utilising offshore tax havens and legitimate investment fund
accounts.
In a general sense, the Kefauver Committee also realised criminal prohibitions were
often a rather blunt and ineffective means of combating interstate economic
conspiracy such as that involving illegal gambling. A package of legal remedies was
necessary including civil law actions and licensing regimes. Arguably therefore the
legacy of the Kefauver Committee can be seen in the Racketeer Influenced and
Corrupt Organizations Act of 1970 (RICO), a celebrated United States federal law
that provides for extended criminal penalties and a civil cause of action for acts
performed as part of an ongoing criminal organization and aims to eradicate
organized crime by attacking the sources of its revenue, such as illicit gains and
laundering of monies through gambling or bookmakers.
In sum, the most enduring element of the collective Kefauver hearings was that they
illustrated that and ingrained ethos of sports corruption nationally must be indexed
against, and is generally reflective of, poor governance and accountability in key
self-regulatory, political and even law enforcement authority.
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3. Money Laundering through the Football Sector by the FAFT
In July 2009, the Financial Action Task Force published a major student on money
laundering through the professional football industry (FAFT 2009). The study
claimed that money laundering through the football sector was “deeper and more
complex that previously understood” (FAFT, 2009, p4) and highlighted weaknesses
in football’s governance structures which made it attractive to criminal syndicates
and including: private equity investment in or sponsorship of football clubs; third
party ownership of the players’ economic rights; unregulated agents manipulating
the transfer market; and tax evasion by way of the exploitation of players’ image.
The FAFT Report also highlighted sports betting as an area susceptible to money
laundering (FAFT, 2009, pp24-25). In this, the FAFT Report made four points of
interest.
First, it noted a matter that is sometimes underplayed in the debate on illegal betting
and match fixing: sport has always had an “ambiguous“ and even interdependent
relationship with betting. The FAFT Report pointed out that betting has historically
been an important revenue source for sport in many countries (through, for instance,
state imposed betting tax levies redirected to sport’s benefit). Indeed for some sports
e.g., horse racing, betting is the sport’s raison d'être. In a more modern sense, as
traditional sources of sponsorship for sport (such as tobacco and drinks companies)
have been prohibited from being commercially associated with sport on public
health grounds, sports betting companies have filled the gap left on a club’s jersey.
The potential conflict of interest here is a matter the needs further debate. In the
same year as the FAFT was published the Court of Justice of the European Union
observed as follows Case C-42/07 Liga Portuguesa de Futebol [2009] ECR I-7633 at
para [71]
“Moreover the possibility cannot be ruled out that an operator which
sponsors some of the sporting competitions on which it accepts bets [the
stated case involved Bwin, a well-known European based on-line gaming
undertaking and significant sponsor of football, basketball and motor sport
clubs and competitions], and some of the teams taking part in those
competitions may be in a position to influence their outcome directly or
indirectly and thus increase its profits.”
The second point of interest is that the FAFT Report admitted the while problems
linked to betting on sport “are not new”, the increasingly transnational nature of the
betting industry and the “use of the Internet for online betting further increase the
risk of money laundering” (FAFT, 2009, p24). In this, the FAFT reiterated a point
made earlier in this essay: the attractiveness of the gambling markets to criminals as
a means of money laundering (and concomitantly the difficulties in combatting it)
must be seen in context and namely that the global gambling market is largely a nontransparent and heterogeneous market with a mix of private and state companies
acting both nationally and internationally and with varying degrees of regulation
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ranging from the liberal to the prohibitionist and frequently operating online and
offshore or both. The hotchpot nature of the global gambling industry means that
proposals for a World Anti-Corruption Agency along the lines of the World AntiDoping Agency’s remit (that of harmonising anti-doping policies in global sport) is
distractingly ambitious.
The third point of interest is that the FAFT focused on the involvement of Asian
criminals and the region’s gambling markets as a source of illegal football betting. In
this regard, the FAFT report highlighted the successful actions of Interpol in
combating illegal gambling activities of criminal syndicates in Asia – collectively
called “Operation Soga”. According to Interpol’s “Integrity in Sport” website, as of
2013, the four Soga operations since 2007 have resulted in 2,360 successful raids and
the closure of illegal gambling dens which handled illegal bets worth more than
USD 2 billion; and the seizure of more than US$27 million in cash from illegal
gambling operators.
The final point of interest from the FAFT report is the view that “illegal football
gambling does not necessarily only involve Asian criminals. On the contrary, most
of the Asian bookmakers are professional and well organised companies with a lot
of expertise in the field” (FAFT, 2009, p25). Problems arise because such bookmakers
rarely deal directly with large, criminally exposed punters, but only by means of a
network of intermediaries. This network can stretch from criminal syndicates based
in Asia to gangs based in Eastern Europe who in turn target players and clubs for
fixing purposes. This is an important point. Some commentators are dismissive of
any hope of confronting the match fixing threat to sport because they say it emanates
from the unregulated Asian gambling markets and yet it must be remembere that
Asian bookmakers, although not as tightly supervised as those in European
jurisdictions, are not operating in a totally “hidden market”. Many, in jurisdictions
such as Singapore, operate openly and professionally. It is the criminal, shadowy
web of intermediaries wherein lies the problem (Hill, 2008, 2013).
Conclusion: If Sport goes it alone, it will fail
Transnational organised crime gangs operate within the abovementioned web of
gambling intermediaries, and these gangs have identified sports organisations as
providing excellent cover for their activities (SportAccord, 2013, p34 and Australian
Crime Commission, 2011 and 2013): sports organisations and players generally have
a good public image and therefore investment in a club presents both money and/or
“image” laundering opportunities for criminals; sports bodies sometimes suffer from
intrinsic structural and governance fragilities and are either weak in international
organisation (e.g., professional boxing) or, with unnecessary fierceness, protect their
domestic regulatory independence and hence seek to operate outside the norms of
domestic public law (e.g., football) despite receiving million in public monies to
facilitate large scale international sport events. In sum, this means that sometimes
there is less transparency and fewer controls in the close-knit regulatory landscape
of international sport (Transparency International, 2009).
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Moreover, and at both a national and international level, sports governing bodies are
only now beginning to operate in a collective, consensual manner to address this
integrity threat to sport and thus at present there are markedly differing levels of
integrity oversight in professional sport. In addition, transnational organised crime
syndicates, experienced in the trafficking of narcotics, are aware that individual,
aspiring professional athletes, many of whom lack significant formal education, may
be susceptible to exploitation. Many young athletes are not well represented, if at all,
by their (un)regulated agents. Meaningful, representative player unions do not exist
in some sports and thus some athletes are vulnerable to being “groomed” as
“gambling mules” for future criminally-related betting scams.
With specific regard to money laundering and match fixing but also to the match
fixing in sport debate more generally, sport should look to eternal expertise and
should do so in two ways.
First, money laundering through gambling outlets results in financial and credibility
detriment to gambling companies and the industry’s regulators. Consequently both
have advanced means of tracking and mitigating the money laundering threat,
which could be usefully adapted to sport’s needs e.g., see the anti-money laundering
guidelines of the Remote Gambling Association (a London & Brussels-based trade
association whose membership are all licensed for gambling purposes in Europe and
includes most of the world’s largest and most respected Internet gambling
companies) and the guidance provided by the UK Gambling Commission on antimoney laundering initiatives. Both are examples of best practice (RGA, 2010 and UK
Gambling Commission, 2013).
Second, and in a wider conceptual way, this brief essay argues that match fixing in
sport should be placed firmly within the international discourse on transnational
financial services fraud. This would not, as some might have it, unnecessarily
conflate or exaggerate the seriousness of match fixing in sport; rather the recognition
of the true global extent of match fixing in sport would be the first necessary step in
the fight back by sport against the fixers. It would allow sport access (a) the anticorruption research (funded by entities such as the EU Commission (2011, para 4.5)),
the resources (that can be brought to bear by organisations such as the
aforementioned UNODC); and (b) the expertise available at inter-governmental level
(epitomised by that carried out by FAFT and Interpol) that already exists in this area.
Crucially, by properly describing match fixing in sport as being characteristic of the
opportunism of transnational organised crime syndicates, this might also help
explain at governmental level how the integrity threat to sport is not just something
that narrowly concerns the insularity or specificity of sport but is also one that
necessitates wider societal concern and deeper investigative resourcing.
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